Judicial Watch, a conservative watchdog organization, has sent a letter to California Secretary of State Alex Padilla on behalf of the Election Integrity Project, noting that there are 11 counties in the state with more registered voters, and alleging that the state may be out of compliance with Section 8 of the National Voter Registration Act (NVRA).

The letter reads, in part:

NVRA Section 8 requires states to conduct reasonable list maintenance so as to maintain an accurate record of eligible voters for use in conducting federal elections.1 As you may know, Congress enacted Section 8 of the NVRA to protect the integrity of the electoral process. Allowing the names of ineligible voters to remain on the voting rolls harms the integrity of the electoral process and undermines voter confidence in the legitimacy of elections.

…

As the top election official in California, it is your responsibility under federal law to coordinate California’s statewide effort to conduct a program that reasonably ensures the lists of eligible voters are accurate.

Judicial Watch lays out the specifics: “[T]here were more total registered voters than there were adults over the age of 18 living in each of the following eleven (11) counties: Imperial (102%), Lassen (102%), Los Angeles (112%), Monterey (104%), San Diego (138%), San Francisco (114%), San Mateo (111%), Santa Cruz (109%), Solano (111%), Stanislaus (102%), and Yolo (110%).” The letter notes that the percentage in L.A. Country may be as high as 144%.

The letter contains a threat to sue the Secretary of State if Padilla does not remove from the rolls “persons who have become ineligible to vote by reason of death, change in residence, or a disqualifying criminal conviction, and to remove noncitizens who have registered to vote unlawfully.” It gives Padilla 14 days to respond, and 90 days to correct alleged violations of the law.

Padilla has been one of the main voices in opposition to President Donald Trump’s Presidential Advisory Commission on Election Integrity, refusing to share voter data with it on the argument that doing so would “legitimize false claims of massive election cheating last fall.”

President Trump has claimed that he would have won the popular vote in the 2016 presidential election if not for illegal voting, and his administration has singled outCalifornia as a possible contributor to that margin.

The Election Integrity Project is a California-based volunteer organization that monitors voting irregularities.